Daniel W. McKeel GSI SEC co-petitioner bibliography 12/8/12

Comments from Daniel W, McKeel, Jr. M.D, regarding the agenda for the August 28,
2012, Meeting of the Advisory Board's Work Group on TBD 6000

(August 21, 2012)

x... PDF 54 KB (3 pages)

Comments from Daniel W. McKeel, Jr. M.D. regarding the SC&A Memo: Alternative
Model for the Calculation of Uranium Intakes at GSI
(August 5, 2012)

1. PDF 9 MB (28 pages)

Comments from Danie! W. McKeel, Jr. M.D. regarding the General Steel Industries
Special Exposure Cohort Petition-00105

(July 26, 2012)

L PDF 589 KB (14 pages)

Comments from Daniel W. McKeel, Jr.. M.D. regarding the General Steel Industries
ial Exposure Col ition-001

(July 10, 2012)

.. PDF 7 MB (24 pages)

Comments from Daniel W. McKeel, Jr. M.D. on David Allen DCAS Memo Dated June 8,

2012 to the TBD-6000 Work Group of the ABRWH in Response to the SC&A
Di ion Paper a [Intake Dos:

(June 13, 2012)

bs PDF 439 K8 (6 pages)

comments from ie! W. McKeel, Jr.. M.D. on SC&A ssion Paper {30/12
titled "Update of "Review of 'Site Profiles for Atomic Weapons Employers That Worked
Uranium and Thorium Metals - Appendix BB: General Stee! Industries" Battelle-TBD-
6001 ndix BB." Oc tional In! ose
(June 2, 2012)

J POF 7 MB (26 pages)

nts from Daniel W. 1 Jr. M.0. on A Di ion Paper dated 5/30/14
titled "Update of "Review of ‘Site Profiles for Atomic Weapons Employers That Worked
Uranium and Thorium Metals - Appendix BB: General Steel Industries" Battelle-TBD-
6000, i “ Occupational Internal
(June 1, 2012)
3s PDF 7 MB (26 pages)



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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concems under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this transcript is for information only and is subject to change.

3,300-pound objects. So they definitely 4,
needed to be picked up with a crane and a
chain.

The other two types of metals we
know are billets, uranium billets. We do not
know the size of those. I don't think anybody
does. And it was commented by Dave Allen, I
think, that a betatron slice, which is
described in one of the six Site Profile
documents for Mallinckrodt, was just the crop.
I think that is definitely not true because
the Mallinckrodt document describes quite
clearly that a person spent long amounts of
time, at first at least, hand-sawing uranium
ingots to get a slice. And SC&A has estimated
they were maybe 4 inches thick, 18 inches in
diameter, 12 to 18 inches in diameter.

Nobody really knows is the answer.
And nobody knows the size of the billets. And
nobody knows what mixture was sent to

Mallinckrodt, although I did introduce a

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS



This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concems under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information has
been redacted as necessary. The transcript, however, has not been reviewed and certified by the Chair
of the Advisory Board for accuracy at this time. The reader should be cautioned that this transcript is for
information only and is subject to change.

TABLE OF CONTENTS
AGENDA ITEM
Welcome - Dr. James Melius, Chair

GSI SEC Petition Update -
Mr. Dave Allen, NIOSH
Dr. Paul Ziemer, WG Chair
Petitioners: Dan McKeel
Patricia Jeske

Pantex Plant SEC Petition (1984- 1991)
Stuart Hinnefeld, NIOSH
Mr. Joe Fitzgerald, SC&A
Petitioner: Sarah Ray

Baker-Perkins (Saginaw, MI) Technical
Basis Document Review
Dr. Henry Anderson, WG Chair

Weldon Spring Plant (Weldon Spring,
MO) SEC Petition
Dr. Richard Lemen, WG Chair
Mr. Stuart Hinnefeld, NIOSH
Petitioners: Tina Triplett

Mound Plant SEC Petition (1972,
1975-1976) (83.14
Dr. James Neton, NIOSH

Mound Plant SEC Petition (1980-2007)
Dr. James Neton, NIOSH
Ms. Josie Beach, WG Chair

Board Work Session
Dr. James Melius, Chair

United Nuclear Corp. (Hematite, MO) SEC
Petition
Dr. Henry Anderson, WG Chair
Petitioner: Clarissa Eaton

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE... N.W.

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165
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270



ee —_ ed

This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been |
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable |
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this transcript is for information only and is subject to change.

1 survey the rest of the plant at all. 46
2 The remediation took a week. And
3 they found uranium and cleaned it up in the
4 old betatron building only. No uranium is
5 found in the new betatron building. They
6 found some alpha uranium activity on _ the

“I

floors, which they had to chip out, in the

8 vents and in the small industrial vacuum. And
9 it's that piece of data that the washings
10 relate to. And I'll mention a little bit more
11 of that in a few minutes. But we do know of
12 one additional set of washings, power
13 washings, that was done in both the old and
14 new betatron buildings in 1973, just at the
15 time of plant closure. And this was an
16 eyewitness account by a worker who is very
1? well-known to this Board. So there were
18 multiple power washings of the old and the new
19 betatron buildings that we have I think well
20 documented.

21 A point that is really overlooked

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
4323 RHODE ISLAND AVE., N.W.



McKeel

EXHIBIT 4

Dan McKeel
PUBLIC COMMENT to
ABRWH in Knoxville:

12-11-2012


DWM_9.19.12_abrwh_p39-53.txt
INTRODUCTION:

Daniel W. McKeel, Jr., M.D., the GSI SEC-@@10@5 co-petitioner, addressed the
ABRWH 86th meeting in Denver, Colorado, on September 19, 2012. Here is his
testimony that runs from page 39 line 7 to p55 line 13. There was an
accompanying slide presentation that is attached to this transcript excerpt.

TESTIMONY OF DR. MCKEEL, PAGES 39-53
CQUOTE)

p.39

1 were -- the highest was 11 dpm per cubic 2 meter, which sort of falls into the
same range 3 of the limited samples from Leblond and I 4 would think also
reflects a low-exposure 5 situation based on the job task. 6 CHAIRMAN MELIUS
Any other 7 comments or questions at this point? 8 (No response.) 9 CHAIRMAN
MELIUS: Okay. Let's 1@ hear from the petitioner, see if we have any 11 questions
for them. I'm not sure if it’s one 12 or two people speaking. And then we will
come 13 back and have further discussion. So don't go 14 too far away, Dave. 15
DR. McKEEL: Hello, Dr. Melius. 16 This is Dan McKeel. Can you hear me? 17
CHAIRMAN MELIUS: Yes, we can. Go 18 ahead, Dan. 19 DR. McKEEL: Thank you. Are my
2@ slides ready to go?

p4a

1 DR. McKEEL: Okay. 2 CHAIRMAN MELIUS: Stu is getting 3 them. 4 DR. McKEEL

Okay. 5 CHAIRMAN MELIUS: I will let you 6 know when. Here we go. Okay. Your
title 7 slide is up now. 8 DR. McKEEL: Okay. Well, let me 9 just make a short
introduction and to thank 1@ the Board for being so generous with letting 11 me
submit materials to them on GSI. In the 12 next ten minutes or so, I will try to
cover 13 the highlights. But I do want to comment 14 while it's fresh in mind
for everybody on a 15 couple of things that just came up in the 16 preceding
presentations by Dr. Ziemer and by 17 Dave Allen. 18 The first thing is that the
ingots 19 and the dingots from Mallinckrodt, the size is 20 very well known. And
basically they were

p41

1 needed to be picked up with a crane and a 2 chain. 3 The other two types of
metals we 4 know are billets, uranium billets. We do not 5 know the size of
those. I don't think anybody 6 does. And it was commented by Dave Allen, I 7
think, that a betatron slice, which is 8 described in one of the six Site
Profile 9 documents for Mallinckrodt, was just the crop. 10 I think that is
definitely not true because 11 the Mallinckrodt document describes quite 12
clearly that a person spent long amounts of 13 time, at first at least, hand-
sawing uranium 14 ingots to get a slice. And SC&A has estimated 15 they were
maybe 4 inches thick, 18 inches in 16 diameter, 12 to 18 inches in diameter. 17
Nobody really knows is the answer. 18 And nobody knows the size of the billets.



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This transcript of (he Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personaily identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this lime. The reader should be
cautioned that this transcript is for information only and is subject to change.

Labor because it would really help to have 339

some place to go. Please, if there was any
way we could get that to happen, it would be
wonderful.

And, lastly, I would like to add
great appreciation to Terrie Barrie and
{identifying information redacted] for all the
work that they put in, you know, another two
people that they don't get any financial gain
from this. And they put in hours and hours of
work and dedication and love into this. And I
just want to thank them for all their work.

So thank you. And thank you to
you.

CHAIRMAN MELIUS: Thanks. Okay.

Anybody else in the room wish to
make public comments?

(No response.)

CHAIRMAN MELIUS: Okay. If not,
thank you for attending. And we will be

following up. And we will reconvene tomorrow

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE... N.W.



uranium. 17
And the other thing is none of the 18 relevant records that would contribute to

the 19 accurate bounding have been recovered from 2@ Mallinckrodt on the work
done at GSI.

ps2

1 NIOSH has made a lot of errors of fact in 2 Appendix BB that still need to be
addressed. I 3 believe that the NIOSH betatron, the steel 4 casting activation,
and the uranium intake 5 models are not valid for reasons I have put 6 forward
and, therefore, not bounding. There 7 has been extreme underestimation of the
exotic 8 mixed activation fission radionuclides that 9 were discussed
prominently at Rocky Flats 10 yesterday that were caused by a bombardment of 11
uranium and the steel castings for the 12 betatrons. At those high MeV, both
things 13 occur. 14

And NIOSH used only iron-59 as an 15 activation product, where we sent you 16
literature documenting that there are at least 17 30 different radionuclides
some with 18 half-lives that were days and weeks and much 19 longer than they
assigned for Fe-59, 20

And, finally, with respect to

ps3

1 scenario, I will point out that one of the 2 main references cited by NIOSH
and SC&A from 3 TBD-600@0 is that by Adley, et al., for the 4 Hanford melt plant
in 1952. And that showed 5 that uranium rod handling caused intake doses, 6 I
quote, intake doses 2.5-fold higher than the 7 permitted limits. So they may
have been 8 relatively low, but they were two and a half 9 times what radiation
safety limits at the time 10 would permit. 11

So I thank you and appreciate your 12 attention. 13

CHAIRMAN MELIUS: Is the 14 co-petitioner on the line and wish to comment? 15

MS. JESKE: This is Patricia 16 Jeske. And no, I don't have any comments. I 17 do
agree with Dr. McKeel. And I do hope that 18 we can reach a vote and put closure
to this 19 for all of our Class Members. I appreciate 2@ everybody's help. Thank
you so much.

CEND QUOTE)

The TRANSCRIPT ENDS ON PAGE 340 with the adjournment being at 6:26 PM Denver
Mountain time.


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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this transcript is for information only and is subject to change.

So, in summary, then, I think that 52

NIOSH has made a lot of errors of fact in
Appendix BB that still need to be addressed. I
believe that the NIOSH betatron, the steel
casting activation, and the uranium intake
models are not valid for reasons I have put
forward and, therefore, not bounding. There
has been extreme underestimation of the exotic
mixed activation fission radionuclides that
were discussed prominently at Rocky Flats
yesterday that were caused by a bombardment of
uranium and the steel castings for the
betatrons. At those high MeV, both things
occur.

And NIOSH used only iron-59 as an
activation product, where we sent you
literature documenting that there are at least
30 different radionuclides, some with
half-lives that were days and weeks and much
longer than they assigned for Fe-59.

And, finally, with respect to

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLANO AVE., N.W.



DAN MCKEEL GS! PAPER BIBLIOGRAPHY: PAGE COUNT SUMMARY

DOC PAGE

No. Pages

Duplicates

1

13
20
4
9
14
7
43
16
6

3
28
14
24

6
26
26

4
31
36

6

4
14
12

7

3

Attached 1
Attached 2
Attached 3
Attached 4
Attached 5
Attached 6
Attached 7
Attached 8

12/8/12
Page No. Papers | _No. attachments
1 9 0)
2 7 i¢)
3 1 8
4 11 0
5 2 0
30 8
Pages per document Page
DOC page | Pages total
1 132
2 127
3 117
4 130
5 33
539
McKeel Papers by Year
YEAR PAPERS ATTACHMENTS
2012 23 8
2011 Ss 0
2010 1 0
2009 1 0
2008 9 0
2007 1 0

29
1
37
1
24
2

19

Vulaaeanepaee nn ealwwwnwwwwwwinNnnnnnnnile reer eeppey

10
23

TOTAL
Less Attached!

539

113

426



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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader snculd be
cautioned that this transcript is for information only and is subject to change.

letter from the AEC that said the primary 42

product sent from Mallinckrodt to GSI was
dingots. And that would be the 3,300-pound
metal.

Anyway, the first thing I wanted
to do in the first two slides is to review the
real data that is available right now for the
AEC operational period at GSI from 1953 to
June 1966.

And it really comes down to three
data pieces. The first was there were
Landauer film badges on 89 _ radiographers
between November 1963 and 1966, June. This
represents only 3 percent of the workforce of
3,000 people, represents 1 job out of
hundreds. The radiographers did not wear
their badges outside the betatron buildings.
As a matter of fact, in the 2012 modeling of
betatron doses, they were not even assigned
the highest external doses. And so that's

point one, very limited and nonrepresentative

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS.
1323 RHODE ISLAND AVE., N.W.



Daniel W. McKeel, Jr. TALK
12/11/12 ABRWH KNOXVILLE, TN
-- GS! SEC-00105 PRESENTATION --

[1] Good afternoon - Dr. Melius has again restricted me to a 10 minute presentation
to highlight the 38 white papers of mine | have sent to the TBD-6000 work group and
Board between 2007 and 2011. The 38 papers total 539 pages. | must rely on the
Board having read these papers, only some of which were discussed in any detail in
work group meetings. Often the WG chair simply acknowledged receipt with no further
discussion of the contents. Numerous McKee! GSI Public Comments also have been
added to the written record.

[2] At the September 2012 Board meeting in Denver | presented SLIDES showing
that only six important pieces of real measured external or internal monitoring data have
been identified for the GSI Illinois site, as follows:

+ Aseries of 1958-66 AEC MCW purchase orders to do Betatron NDT x-ray

work. No P.O.’s have yet been discovered for the 1953-early1958 period;

+ A 1962 NCC limited radiologic survey of the 2 Co-60 sources in building 6;

+ A 1968 radiologic survey by GSI personnel of the New Betatron building
with a larger Co-60 gamma source;
Two 1962 and 1963 NCC radiation film badge reports from two workers;
89 GSI radiographer Landauer film badge reports 1963-1966. These data
represent only 3% of the total annual work force of about 3,000 workers,

and they are all males doing a single job out of hundreds at the plant (10%
of the GSI workforce was estimated to be female);

Uranium dust concentrations were measured in and around a small industrial
vacuum in 1992 in the Old Betatron facility during the DOE/FUSRAP uranium
cleanup that closed the residual period;

[3] ALL of the other monitoring data at GSI is either surrogate or modeled using

MCNPX. NIOSH and SC8&A have no Betatron x-ray data, surrogate or measured, from

-1-


This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information has
been redacted as necessary. The transcript, however, has not been reviewed and certified by the Chair
of the Advisory Board for accuracy at this time. The reader should be cautioned that this transcript is for
information only and is subject to change.

DAVID B. RICHARDSON, Member
PRESENT: (CONT. )

GENEVIEVE S. ROESSLER, Member

PHILLIP SCHOFIELD, Member

PAUL L. ZIEMER, Member

THEODORE M. KATZ, Designated Federal Official

REGISTERED AND/OR PUBLIC COMMENT PARTICIPANTS:

ADAMS, NANCY, NIOSH Contractor
ALEXANDER, TERRY
ALLEN, DAVE, DCAS
BARRIE, TERRIE

BROCK, DENISE, DCAS
BURGOS, ZAIDA, NIOSH
CARROLL, STEPHANIE
DOBROVOLNY, MARK
EATON, CLARISSA*
EVASKOVICH, ANDREW
FITZGERALD, JOE, SC&A
GALLAGHER, DEE

GLOVER, SAM, DCAS
HINNEFELD, STU, DCAS
JERISON, DEB

JESKE, PATRICIA*
KENNEY, CECELIA, DOE
KINMAN, JOSH, DCAS
KOTSCH, JEFF, DOL
LEWIS, GREG, DOB

LIN, JENNY, HHS
MAKHIJANI, ARJUN, SC&A
MAURO, JOHN, SC&A*
MAUSER, TERRIE*
MCCFEE, MATTHEW, ORAU Team
MCKEEL, DAN*

NETON, JIM, DCAS

RAY, SARAH*
RUTHERFORD, LaVON, DCAS
STIVER, JOHN, SC&A
TAULBEE, TIM, DCAS

NEAL R. GROSS
COURT REPORTERS ANO TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.



Daniel W. McKeel GSI SEC co-petitioner bibliography 12/8/12

= Submission from Daniel W. McKeel, Jr.. M.D. requesting that technical documents and
comments he made between /12 and 3/28/12 be posted to Docket 14!
the Advisory Board
(May 21, 2012)
ib. PDF 3 MB (4 pages)

e Attachment 1: Critique of the NIOSH January 2012 White Paper "Dose Estimates
For Betatron Operations"
ih. PDF 7 MB (31 pages)

Submission
i PDF 8 MB (36 pages)

Attachment 3: Corrected Concrete Activation Isotopes, SEC Issues 5 and 6 From
David Allen’ "P nwar v
jh PDF 4 MB (6 pages)

A 4: Memo - E-mail fr i RE: MCN:
code
i PDF 858 KB (4 pages)

. hment 5: Dan 2! GS1-00105 Co-Petitioner Comments, Part 1 i
Allen Addendum 3 to his January 2012 Betatron Operations White Paper (via e-
mail)

j}. PDF 9 MB (14 pages)

« Attachment 6: Daniel McKeel GS! Co-Petitioner Comments, Part 2: David Allen
January 2012 Betatron White Paper, ADDENDUM 3: New Betatron Scenario For
rE res: Interpretation of McKeel-Landauer Program 2!
Fi March 25, 2012 Daniel W. McKeel, Jr.
i PDF 8 MB (12 pages)

« Attachment 7: McKeel Petitioner Comments on NIOSH Allen August 2011 and
January 2012 Path Forward For GSI Whit rf ddenda to Ther
g PDF 4 MB (7 pages)

= Attachment 8: E-mail from Dan McKeel to Ted Katz - Request to distribute TBD-
6000 work group information to full Board
is. PDF 2 MB (3 pages)



SLIDE 1

TITLE: Real data AEC operational period 1953-June 1966

. Landauer film badges on 89 radiographers Nov 1963-1966;
3% of workforce of 3000, one job out of hundreds, not assigned
the highest external dose, not worn in plant outside OBB/NBB

° 1962 one time survey of photons in Bldg 6 radiography Co-60
by Nuclear Consulting Corp. (NCC)

. MCW Uranium Division purchase orders for Betatron NDT
radiography 1958 through June 1966 (1953 through Feb 1958
missing) -- No uranium weights or information on percentage
or numbers of 3300 Ib dingots/ingots, billets and slices; all
shipping manifests and weights and x-ray records missing



Keel, Jr, M.D... on the G al Industries SEC

(December 12, 2009)
}. PDF 7 MB (10 pagos)

Note: The documents mentioned in the above comment can be viewed on the US.

External Link: http://adame
ssion asp?Accessi

nNumber=ML

Acces

= Comments on the Site Profile for Atomic Weapons Employers that Worked Uranium and
Thorium Metals document, Appendix BB -- General Steel Industries

* Critique to NIOSH of Appendix BS to Battelle TBD-6000 for the General Stee!
Industries SEC AWE Site

NIOSH written response to “Critique to NIOSH of Appendix BB to Battelle TBD-
6000 for the General Steel Industries SEC AWE Site"
i. PDF 1 MB (11 pages)

« Comment and Reply Re: Appendix BB to Battelle TBD-6000 for the General Stee!
Industries Site. Submitted to OCAS and its Director, Larry Elliott, as a public
comment to the July 17-19. 2007, ABR'WH meeting and as a public docket
comment to the Appendix BB for posting on the OCAS Web site
jh PDF 1.1 MB (23 pages)

NIOSH written response to "Comment and Reply Re: Appendix BB to Battelle
TBD-6000 for the General Steel Industries Site. Submitted to OCAS and its
Director, Larry Elliott. as a public comment to the July 17-19. 2007, ABRWH
meeting and as a public docket comment to the Appendix BB for posting on the
OCAS Web site.”

& PDF 1.2 MB (13 pages)

The first “Critique to NIOSH of Appendix BB to Battelle TBD-6000 for the
General Steel Industries SEC AWE Site” document was contributed by GS{ SEC-
00105 co-petitioner Daniel W. McKeel, Jr. lt incorporates remarks made as an
ABRWH general meeting PUBLIC COMMENT. The written response by NIOSH was
the first and last written response that NIOSH ever made to any of the Dan McKeel
white papers that followed and are listed above in this bibliographic compilation.
The other 3 documents were from John Ramspott, GSI site expert and from NIOSH.

Summary of McKeel Submissions (total papers = 30 + 8 attached papers)

Bibliography Pg. No. of Papers Total pages/ Page | Papers by Years
1 _ 9 2012 all
2 7 2012 all
3 1+ 8 attachments 2012 all
4 11 2010/11, 2012(5
5 2 2007, 2009



This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information has
been redacted as necessary. The transcript, however, has not been reviewed and certified by the Chair
of the Advisory Board for accuracy at this time. The reader should be cautioned that this transcript is for
information only and is subject to change

*Participating via telephone. 3

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.



McKeel

EXHIBIT 5

Dan McKeel
BIBLIOGRAPHY
of 38 Papers
submitted to the
ABRWH and the
TBD-6000 Work Group
2007-2012

12-11-2012


2008 & 2012 Models Disagree

COMPUTER MODELED ANNUAL PHOTON DOSE
DURING GSI COVERED PERIOD 1953-1966 (Rem/YR)

DATA 2008 2012
SOURCE BETATRON BETATRON
| 1.0-6.3 (App BB)
NIOSH | ND? (SEC ER) 0.2-.62 var.
SC&A mcnpx 12.4 - 13.6 1.35
2007-2008
DATA SOURCE OTHERS 2012 LAYOUT
1.73 (App BB)
NIOSH 0.417 (note 1] 1.02-2.03
SC&A mcnpx [see note 2] 9.20

Note 1: Annual dose assigned to only 1 of 3 non-Betatron worker
exposure scenarios in SEC-00105 SEC evaluation report.

Note 2: SC&A review of Appendix BB, 4/21/08 Betatron doses
bounded layout men and Co-60 operators which in turn bounded
chainmen and all other workers. No actual values given for this
large subset of the GSI work force.

3 ND = not done; no annual dose values given in SEC ER



McKeel

EXHIBIT 7

Dan McKeel
Talk to the 86th
ABRWH in Denver
September 19, 2012

Transcript Pages 39-53
(original + condensed)

12-11-2012


Slide 4

TITLE: Reasons GSI deserves an SEC recommendation by the Board
Part 1

. Operational period: No MCW uranium purchase orders 1953-Feb 1968;

° Limited real data: 3 items AEC contract years; 3 items residual years;

. Nonexistent intake data sampling: breathing zone, general air, process;
° No urinary uranium bioassay for radiographers or anyone in workforce;
° Most of GSI work force should have been badged; worked on activated

steel: 3% badged during 3 of 13 years of operation period; 0.7% were
badged during 8 of 20 years of the residual period (99.3% no badge);
97% of GSI work force never badged 1953-1966. Not representative;

’ Zero monitoring of beta or neutron doses at GSI 1953-1993;

. MCNPx models not validated by any real measurements of Betatron
skyshine, activation products; results differ wildly with SC&A and over
time: Betatron operators >~10-fold> Layout 2008; reverse found in 2012.

° NIOSH has not used valid models to bound all GSI sources: Ra-226
(2 sources), Co-60 (3 sources); Ir-192 (1 source); (2) 250 Kvp X-ray units.


a) GSI used only Mallinckrodt ingots, uncropped dingots, “betatron slices,” and
some billets. The surrogate Allen-NIOSH sites used uranium dingots, billets, derbies
and slugs but no ingots or betatron slices.

b) The surrogate sites did not perform 24-25 Mev Betatron x-ray radiography on
their uranium. That is why the AEC was actively collaborating with GSI in 1952 to
imporve x-ray images soon after the first Betatron was put into operation in January
1952.

c) The DCAS surrogate sites have not been “stringently justified.” Allen admits
this, saying he will do the justification in a revised Appendix BB at some undefined time
in the future. This is not acceptable: NIOSH needs to be able to demonstrate stringent
justification today, before this full Board votes on GSI SEC-00105.

[7] Six GS! SEC issues were moved to the Appendix BB issues matrix as was
mentioned at the 11/28 WG meeting. Those issues were deliberately left open to be
resolved and closed later in 2013. This was a poor decision, because they were still

SEC issues that needed to be resolved prior to the final recommendation.

[8a] There is zero monitoring of uranium air intakes or urine uranium bioassays,
or of GSI external Beta and Neutron doses, for any GSI site worker 1952-1993.
SC&A and NIOSH admit this fact.

[8b] The only film badge data for GSI is for radiographers 1963-73. The Landauer
GSI film badges only read photons. Radiographers only wore their badges part time.
97% of the GS! work force of 3,000 covered in the SEC-105 class were never badged.
They should have been because Betatron-activated castings were all over the plant.

[9] TIB-70 surrogate data is not appropriate for modeling GSI residual period
uranium intakes. The TIB is based on a known start value that steadily declines. At GSI
there were periodic uranium dust resuspension cycles due to power washing both
Betatron buildings, renovation construction at the New Betatron facility, and new


any site, to validate their computer model results. These key data seem not to exist. GSI
is an absolutely unique site in this regard.

[4] Aslide we showed in September showed very disparate SC&A and NIOSH
computer modeling results over time, comparing 2008 with 2012 data, and between the
two entities. Model agreement ranges between 2-fold and 12-fold between entities with
some concerning ratio reversals. The peer review literature standard for validating
computer models is that agreement with real measured data should be + 10 to 20
percent, not 200 percent.

[5] The SC&A revised GSI SEC-00105 issues matrix | received was dated
November 30, 2012, two days after the TBD-6000 work group met. Another GSI SEC

matrix version dated Dec. 5th has been posted for this meeting. Those matrices have
not been discussed by Dr. Ziemer's work group.

+ | now address the November 28, 2012, TBD-6000 work group meeting draft
transcript that DFO Ted Katz provided to me last Friday. My two GSI petitioner
colleagues, and — carried the ball at the Nov. 28 meeting
for reasons | made clear in a protest letter Ted Katz read into the record and then

circulated to all of you. Today, | stand by every word in that letter. The GS/

claimants have been treated very unfairly by the TBD-6000 work group.

[6] |The SC&A August 2012 analysis of Allen's 3 NIOSH AWE surrogate sites failed

to meet 4 of 5 Board surrogate data criteria. However, by some magical reasoning that

baffles the GSI petitioners, on Nov 28, 2012, SC&A had reversed positions completely,

so that by now 5 of the 7 Allen-DCAS sites satisfied ALL 5 Board surrogate data criteria.
I strongly support the SC&A August analysis for the following reasons:

+ The Allen surrogate sites are not comparable to GS! uranium operations or the forms

of uranium used. To be specific:


Daniel W. McKeel GSI SEC co-petitioner bibliography 12/8/12

Daniel W. McKeel, Jr., M.D.

BIBLIOGRAPHY OF MCKEEL PAPERS
Submitted to the ABRWH

General Steel Industries (GS!)
NIOSH Docket 140

Comments Received:

« Comr

ment: / batatron ft:
(November

= Comments from Daniel W. McKeel. Jr. M.D. regarding NIOSH/DCAS: Evaluation of
Additional Air Sample Data Applicable to GSI
(November 10, 2012)
4. PDF 4 MB (20 pages)

Addendum 1
(November 10, 2012)
4 PDF 1 MB (4 pages)

Addendum 2
(November 26, 2012)
3. PDF 6 MB (9 pages)

= Comments from Daniel W. McKeel, Jr.. M.D. regarding his presentation at the
September 19. 20 visory Board meeting
(September 21, 2012)
x. PDF 3 MB (14 pages)

= Co-Petitioner Daniel W. McKeel, Jr, MD Pres
Petition 105
(September 18, 2012)
t. PDF 437 KB (7 pages)

ation: General Steel Inc

ries SEC

= Annotated transcribed notes submitted by Daniel W. McKeel, |.D. from the August
28, 2012, Meeting of the Advisory Board's Work Group on TBD-6000
(September 2, 2012)
& PDF 897 KB (43 pages)

= Comments from Daniel W. McKeel, Jr. M.D. regarding NIOSH: Use of Surrogate Data
at GSI Response to SC&A Review Dated July 16, 2012
(August 26, 2012)
«. PDF 4 MB (16 pages)

Addendum

(August 26, 2012)
yt. PDF 1 MB (6 pages)


McKeel

EXHIBIT 2

GSI SEC-105 talk to
ABRVWH in Knoxville:

Slide comparing SC&A
with NIOSH Modeled
External Betatron &

Layout Worker Doses
2008 vs 2012

12-11-2012


McKeel

EXHIBIT 6

Dan McKeel
Talk to the 86th
ABRWH in Denver
September 19, 2012

12-11-2012



Dragon, Karen E. (CDC/NIOSH/EID)

From: DanMckKeel:

Sent: Friday, December 14, 2012 12:56 PM

To: Katz, Ted (CDC/NIOSH/OD), melius@nysliuna.org; NIOSH Docket Office (CDC)
Ce: danmckee

Subject: GSI McKeel info for ABRWH members not voting 12/19/12 & Docket 140
Attachments: MCKEEL_ToABRW+_9.14.12.pdf

Ted Katz, DFO

Dr. James Melius, Chairman, ABRWH
NIOSH Docket 140 (GSI)

Attachment: <MCKEEL_ToABRWH_9.14.12.pdf> 1.9 MB
Dear Ted and Dr. Melius,

Ted Katz, may | ask you to please ensure that all Board members, especially those who have not yet had an opportunity
to vote on the GSI SEC-00105 petition, receive the attached PDF cover letter and the combined 7 Exhibits. The contents
are my presentations to the full Board on 9/19/12 and 12/11/12, my testimony on 9/19/12 (pages 39-53 of the transcript),
my 12/11/12 Public Comment, the external dose slide | mentioned 12/11/12 highlighting very disparate SC&A and NIOSH
computer modeled doses for Betatron -vs- Layout workers in 2008 and 2012, and a list of my papers presented to the
Board and TBD-6000 work group concerning GSI. | feel it is very important that the absent Board members on 12/11/12
get this information right away, before they cast their final votes. Thank you.

NIOSH Docket Office, may | please request you consider the attached PDF file to be posted on the DCAS website under
Docket 140 (GSI). Thank you.

Sincerely,
-DanMcKeel 12/14/12

Daniel W. McKeel, Jr, MD
GSI SEC-00105 Co-petitioner


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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this transcript is for information only and is subject to change.

said, there had never been any general air
sampling, breathing zone samples, process
sampling for uranium ever at GSI or by DOE
until that 1993 survey.

Okay. If I could go to the slide

CHAIRMAN MELIUS: And, Dan, I'll
ask you to please move it along.

DR. McKEEL: I will.

CHAIRMAN MELIUS: We have
something else scheduled at this time.

DR. McCKEEL: Okay. Thank you,
Jim. I don't think I've used my ten minutes,
but I was trying to address questions --

CHAIRMAN MELIUS: Yes, you have.

DR. McKEEL: -- that weren't
answered by anybody during the discussion
period. So the key events during the residual
period I would like to point out were the
power washings for the old and new betatron

buildings and that multiple steel companies

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.

48



General Steel Industries SEC-00105 Co-petitioner
Daniel W. McKeel, Jr., M.D.
Letter to the TBD-6000 Work Group

November 28, 2012
To members of the TBD-6000 work group and staff of the ABRWH,

I am today resigning by this letter, in protest, from active participation in the further
deliberations of the ABRWH TBD-6000 work group concerning GSI Appendix BB and SEC-
00105. I have become persuaded that a majority of this work group, together with the DCAS and
SC&A representatives, have exhibited a longstanding persistent personal bias against adequately
evaluating the many substantial scientific contributions made to the ABRWH since 2005 by
myself, other GSI site experts, and the GSI petitioner team. In particular, GSI claimants have
been denied statutory due process under EEOICPA 2000 by not having Appendix BB to Battelle
TBD-6000 revised in a timely and factually accurate manner since it was released in June 2007.

McKeel personal contributions have included: (a) in 2006, being the first person to alert
the ABRWH, DCAS and SC&A to the existence of Landauer film badges for a limited number
of GSI radiographers 1963-1973; (b) to clearly define all of the radiation source terms at GSI in
conformance with DCAS directive OCAS-IG-003, via NRC FOIA 2010-0012, of 1,1016 pages
of AEC by-product license material for GSI; and (c) most recently, via DOE ORO FOIA 2013-
00013, I have shown that during November and December 1952 an active collaboration was
ongoing among MCW, AEC Oak Ridge Office (ORO), and GSI personnel in developing
Betatron radiography uranium imaging techniques that were applied to thin slices of MCW
ingots. A special uranium shield fabricated at MCW was used to contain scattered radiation
fields from the 24 Mev Betatron x-ray beam. The stated purpose was to provide higher quality
x-ray images of AEC/MCW uranium products.

Furthermore, DCAS/NIOSH and SC&A and certain Board members have chosen to
ignore a large fraction of the above and other numerous factual contributions, as oral and written
comments and papers, by the petitioner/site expert and GSI worker/claimant team as reflected in
the transcripts of TBD-6000 work group and ABRWH full Board meetings. Various HHS FOIA
and DCAS personnel have made accessing crucial GSI SRDB documents especially difficult.
For example, obtaining a single copy of Harris-Kingsley 1958 from the CDC/ATSDR FOIA
Office took over two and a half months. Many of my e-mail requests to the TBD-6000 work
group chairman go unanswered by him, except through a surrogate, the DFO or NIOSH SEC
Counselor, neither of whom are the Board or work group secretary per se.

Finally, J am persuaded that, for GSI at least, the SC&A evaluation team has switched
from strongly recommending a GSI SEC for the first 10 years in October 2010, to its present
position in supporting a denial of SEC-00105. SC&A is no longer acting as an effective
oversight agent for the Board, at least in the case of GSL. Rather, it and the work group chair
have become stalwart scientific allies and collaborators with DCAS. The SC&A review paper
released to me on November 26, 2012, at 12:30 p,m, is a prime example of the close
collaboration between SC&A and DCAS. Whereas in their August 2012 paper SC&A found that
use of a uranium slug facility in TBD-6000 failed to pass the 5 Board surrogate data criteria, now
SC&A finds that David Allen’s slug facilities meet all Board surrogate data criteria. Four Allen
Aug/Nov 2012 white paper AWE sites have only 14 claims and 13 dose reconstructions between

-|-


McKeel

EXHIBIT 3

GSI SEC-105 talk to
ABRWH in Knoxville:

McKeel Letter referenced
in 12.11.12 ABRWH talk:
SEC Co-petitioner Resigns
from Participating in
11/28/12 TBD-6000
Work Group Meeting

12-11-2012


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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has nol been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this transcript is for information only and is subject to change.

today that GSI did not analyze the reports 44

they made on the uranium. And that really
goes against what we know about those
operations. They, in fact, did send with
every item radiographed with the betatrons a
checklist of findings.

Now, that's not the final report.
Mallinckrodt may well have analyzed that
further, and I'm sure they did. But the point
is that all of the Mallinckrodt GSI contract
work records, which must be voluminous, every

one of those has been lost. We don't have any

shipping manifestations -- manifests. We
don't have any weights. We don't have any
X-ray records. So that's the operational

period real data.

Now, on slide 2, I review the real
data on residuals contamination period between
July 1, '66 and 1993. And, again, that boils
down to three items, three first bullets, and

the comments by me. They had a one-time 1971

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS.
1323 RHODE ISLAND AVE., N.W.



Slide 5

TITLE: Reasons GSI deserves an SEC recommendation by the Board
Part 2

° Rad safety program rudimentary 1953-1993. NCC license documents are

inadequate based on Watertown Arsenal AEC compliance program;

° NIOSH has no valid Ur intake model 1953-1993; failed surrogate criteria;
At least three previous attempts have failed to pass Board/WG scrutiny.

° NIOSH rejects SC&A alternate model that had to be withdrawn because
Betatron buildings had been washed/cleaned multiple time 1973-1993.

. NIOSH “new” surrogate data not based on uranium ingots/dingots that
was the product MCW primarily sent to GSI for betatron NDT radiography.
NIOSH “better” surrogate sites were not stringently justified: 2 slug and 1
billet facilities proposed; no dingot facilities similar to MCW-GSI;

° NIOSH has never recovered from Mallinckrodt the multitude of Betatron
NDT related records (shot logs, x-ray reports, shipping manifests, etc.)
from GSI generated over 13 years of the AEC uranium NDT contract (only
purchase orders February 1958-June 1966).



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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concems under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy al this lime. The reader should be
cautioned that this transcript is for information only and is subject to change.

had done work within buildings 5 and 6 and 7
through 10, but they required an overhead
crane with a magnet to clean the dust from the
GSI building. So there was lots of it there
and that all of these multiple users in
intermittent operations during the residual
period meant that it would be very difficult
to model and bound residual contamination.

Slide 4 and slide 5. I go over my
reasons why I believe sufficient information
has been presented to vote for the SEC at this
point and that I hope very much the Board
might consider that done.

And I think I have been over the
work that was the real data that was there
during the operational and the limited
periods. I've been over the fact that most of
the workforce, which should have been badged
because of their exposure to activated steel
had not been badged.

The slide you see after four shows

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.

49



2008 & 2012 Models Disagree

COMPUTER MODELED ANNUAL PHOTON DOSE
DURING GSI COVERED PERIOD 1953-1966 (Rem/YR)

DATA 2008 2012
SOURCE BETATRON BETATRON
1.0-6.3 (App BB) ;

NIOSH ND? (SEC ER) 0.2-.62 var.

SC&A mcnpx | 12.4 - 13.6 1.35
2007-2008
DATA SOURCE OTHERS 2012 LAYOUT
1.73 (App BB)

NIOSH 0.417 [note 1] 1.02-2.03

SC&A menpx [see note 2] 9.20

Note 1: Annual dose assigned to only 1 of 3 non-Betatron worker
exposure scenarios in SEC-00105 SEC evaluation report

Note 2: SC&A review of Appendix BB, 4/21/08 Betatron doses
bounded layout men and Co-60 operators which in turn bounded
chainmen and all other workers. No actual values given for this
large subset of the GS! work force.

3 ND = not done; no annual dose values given in SEC ER



operations within Buildings 6 through 10. All this was presented and agreed to by all
parties at the 8/28/12 TBD-6000 WG meeting. TIB-70 does not model this scenario.

[10] Petitioners have submitted three DOE documents that prove GSI Betatron AEC-
MCW operations were underway during November and December 1952. Those
documents have been available since 1998 in the ORO RHTG unclassified database,
and on the FUSRAP website as IL.28-5, and as an ORAU data capture dated April 4-8,
2011. We circulated the key information to the Board, work group, SC&A, NIOSH, and
DOE on Oct. 19th and to DOL on December 5th and 10. The 1952 GSI betatron AEC
collaboration data should have resulted in changing the GSI operational period start
date from Jan. 1, 1953, to Nov. 1, 1952, long ago. We hope that will be done soon.

[11] Member Beach on 11/28/12 offered a motion to recommend approving a GSI
SEC for 1953-62. That motion died because there was no second by the other three
WG members. Dr. Ziemer's slide presentation for today omitted that important fact.

In closing, The TBD-6000 work group, NIOSH and SC&A have had 5+ years since
June 2007 to fully resolve all Appendix BB Rev 0 issues. The SEC-105 deliberations
have taken 4+ years to come to this point. The petitioners, “the fifth vote” in this drama,
from the outset have recommended this Board APPROVE an SEC for GSI from 1953 to
1993. We urge the Board to do the right thing and cast this approval vote today.

- verbal run through #1 ~10 minutes 8:57 to 9:07 CST
- text edits...

- verbal run through #2: 11 minutes

- re-edit taxt to shave 1 minute

- verbal run through #3: no time left...


Daniel W. McKeel GSI SEC co-petitioner bibliography 12/8/12

= Docket 140 (GSI) Submission from Daniel W. McKeel, Jr. M.D.: presentation to the
Advisory Board's Work Group on TBD 6000 on March 15, 2012
(March 17, 2012)
PDF 5.3 MB (29 pages)

« Docket 140 (GSI) Submission from Daniel W. McKeel, Jr, M.D.
(March 11, 2012)
i. PDF 82 KB (1 page)

Docket 140 General Steel Industries: Addendum 1 an
is POF 4.8 MB (37 pages)

* Docket 14 i mission fr niel W. McKeel, Jr. M.D... regarding th:
Jan hite Paper on "Do: imates For Betatr ions"
(February 27, 2012)

i PDF 2 MB (1 page)

Attachment: Critique of the NIOSH January 2012 White Paper "Dose Estimates For
alr ions”

ip. PDF 4.2 MB (24 pages)

Comments from Kent Wall, in November 2, 2014, Advi rd!
Work Group Meeting on TBD 6000

(November 4, 2011)

i PDF 4 MB (2 pages)

Comments from Daniel W. McKeel, Jr., M.0., on a new General Steel Industries related

: lates Betatr
(September 6, 2011)
it. PDF 97 KB (6 pages)
* Comments from Danie! W, McKeel, Jr, M.0.. on the General Stee! Industries SEC
Petition (NIOSH SEC-001
(July 22, 2011)

i. PDF 203 KB (4 pages)

Comments from Danie| W. McKeel, Jr. M.D., on the General Stee! Industries SEC
Petition (NIOSH SEC-00105)
(March 12, 2014)

i PDF 3.5 MB (19 pages)

Comments from Daniel W. McKeel, Jr. M.D.. on the General Steel Industries SEC
Petition (NIOSH SEC-00105)

(February 7, 2011)

i, PDF 2.7 MB (4 pages)

= Comments from Daniel W, McKeel, Jr.. M.D., on the General Steal Industries SEC
Petition (NIOSH SEC-00105)
(April 26, 2010)

yh PDF 163 KB (3 pages)


OR. McKEEL: I will. 9

CHAIRMAN MELIUS: We have 1@ something else scheduled at this time. 11

DR. McKEEL: Okay. Thank you, 12 Jim. I don't think I've used my ten minutes, 13
but I was trying to address questions -- 14

CHAIRMAN MELIUS: Yes, you have. 15

DR. McKEEL: -- that weren't 16 answered by anybody during the discussion 17
period. So the key events during the residual 18 period I would like to point
out were the 19 power washings for the old and new betatron 20 buildings and
that multiple steel companies

p49

1 through 10, but they required an overhead 2 crane with a magnet to clean the
dust from the 3 GSI building. So there was lots of it there 4 and that all of
these multiple users in 5S intermittent operations during the residual 6 period
meant that it would be very difficult 7 to model and bound residual
contamination. 8

Slide 4 and slide 5. I go over my 9 reasons why I believe sufficient information
1@ has been presented to vote for the SEC at this 11 point and that I hope very
much the Board 12 might consider that done. 13

And I think I have been over the 14 work that was the real data that was there
15 during the operational and the limited 16 periods. I've been over the fact
that most of 17 the workforce, which should have been badged 18 because of their
exposure to activated steel 19 had not been badged. 20

The slide you see after four shows

pS@

1 betatron and layout workers that SC&A and 2 NIOSH had generated in 2008-2012
didn't agree 3 with each other at those times, and they 4 flip-flopped. 5
Whereas in 2012, the layout 6 workers had a low dose assigned by SC&A, by 7
2012, the SC&A layout dose had gone to 9.2 and 8 the NIOSH layout dose was only
1.02 to 2. So 9 they didn't agree with each other at that 10 time. 11

And, finally, you can see in slide 12 5 -- I apologize. I am going to go to
slide 13 6. I am going to go to slide 5, finish this 14 up quickly. 15

It is often said there was a 16 robust, relatively robust, radiation safety 17
program between 1963 and 1966 and during part 18 of the residual period at GSI
And we have 19 just given you evidence now that I don't think 20 that was true
compared to other sites. I sent

ps1

1 Watertown Arsenal, which also was in 2 compliance with AEC regulations in
about the 3 same time period as GSI's operational period. 4 And they were far
more extensive than anything 5 that was done at GSI. 6

I have pointed out that NIOSH has 7 no valid uranium intake model for the whole
8 operation and residual periods. NIOSH didn't 9 want to use SC&A's alternate
model. In my 10 opinion, the new surrogate data that NIOSH has 11 proposed
really would probably not pass the 12 surrogate data criteria for the same
reasons. 13 There were two slug facilities and one billet 14 facility. And there
were no dingot facilities 15 similar to GSI and the use of Mallinckrodt 16


This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been

reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable

information has been redacted as necessary. The transcript, however, has nat been reviewed and

certified by the Chair of the Advisory Board for accuracy at this time. The reader should be

cautioned that this transcript is for information only and is subject to change
1 that's why I was asking how many samples there 39
2 were -- the highest was 11 dpm per cubic
3 meter, which sort of falls into the same range
4 of the limited samples from Leblond and I
5 would think also reflects a  low-exposure
6 situation based on the job task.
7 CHAIRMAN MELIUS: Any other
8 comments or questions at this point?
9 {No response.)
10 CHAIRMAN MELIUS: Okay. Let's
11 hear from the petitioner, see if we have any
12 questions for them. I'm not sure if it's one
13 or two people speaking. And then we will come
14 back and have further discussion. So don't go
15 too far away, Dave.
16 DR. McKEEL: Hello, Dr. Melius.
17 This is Dan McKeel. Can you hear me?
18 CHAIRMAN MELIUS: Yes, we can. Go
19 ahead, Dan.
20 DR. McCKEEL: Thank you. Are my
21 slides ready to go?

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS.
1323 RHODE ISLAND AVE., N.W.



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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concems under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this transcript is for information only and is subject to change.

CHAIRMAN MELIUS: Hold a second.

DR. MCKEEL: Okay.

CHAIRMAN MELIUS: Stu is getting
them.

DR. McKEEL: Okay.

CHAIRMAN MELIUS: I will let you
know when. Here we go. Okay. Your title

slide is up now.

DR. McKEEL: Okay. Well, let me
just make a short introduction and to thank
the Board for being so generous with letting
me submit materials to them on GSI. In the
next ten minutes or so, I will try to cover
the highlights. But I do want to comment
while it's fresh in mind for everybody on a
couple of things that just came up in the
preceding presentations by Dr. Ziemer and by
Dave Allen.

The first thing is that the ingots
and the dingots from Mallinckrodt, the size is

very well known. And basically they were

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.

40



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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concems under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy al this time. The reader should be
cautioned that this transcript is for information only and is subject to change.

morning around 8:30. 340

(Whereupon, the above-entitled

matter went off the record at 6:26 p.m.)

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.



SLIDE 2

TITLE: Real data on residual contamination period 7/1/66->1993

One time 1971 radiologic survey of New Betatron Building

by GSI radiation safety officers using 80 Curie CO-60 source.

Landauer film badge data on 19 additional radiographers from

July 1, 1966 to close of GSI operations in 1973 (0.3% work force)
Bechtel/ORNL/DOE uranium radiologic survey of NBB and OBB
between 1988 and 1 week remediation in 1993 of uranium in Old
Betatron building. Uranium alpha on floor, in vents, and in small industrial
vacuum in OBB. No Ur found in NBB. [FUSRAP program]

No survey ever of other GSI buildings that formed along AEC uranium

transport pathway: Weighing scales, loading dock, transfer to rail cars, RR
tracks through Bldgs. 5 through 10 into OBB and NBB that formed only a
tiny fraction of the air volume/space along the uranium contamination

pathway (had uranium ever been surveyed there by GSI or DOE).


1 building. That was done by the GSI radiation 2 safety people and they used an
8@-curie 3 cobalt-6@ source, where the main work done in 4 that building, of
course, was with a 24 or -5 5 MeV betatron. So the source they used to 6 model
the building was not the source that was 7 primarily used in that building. 8
Then they also had additional 9 Landauer film badge data on 19 radiographers 10
during that period from July 1, 1966 to 1973 11 late or early ‘74, when GSI
ceased operations. 12 And, of course, that was a much smaller 13 percent of the
workforce. 14

And, then finally, the data that 15 they had that Dr. Ziemer mentioned was when
16 Bechtel came in and did a radiologic survey of 17 the old and new betatron
buildings. And ORNL 18 surveilled that. And this was done for DOE 19 under the
FUSRAP program. They only surveyed 2@ the new and old betatron buildings, did
not

p46

1

The remediation took a week. And 2 they found uranium and cleaned it up in the 3
old betatron building only. No uranium is 4 found in the new betatron building.
They 5 found some alpha uranium activity on the 6 floors, which they had to chip
out, in the 7 vents and in the small industrial vacuum. And 8 it's that piece of
data that the washings 9 relate to. And I'll mention a little bit more 10 of
that in a few minutes. But we do know of 11 one additional set of washings,
power 12 washings, that was done in both the old and 13 new betatron buildings
in 1973, just at the 14 time of plant closure. And this was an 15 eyewitness
account by a worker who is very 16 well-known to this Board. So there were 17
multiple power washings of the old and the new 18 betatron buildings that we
have I think well 19 documented. 20

A point that is really overlooked

p47

1 the residual period applies to everybody in 2 the workforce. And most of the
people in the 3 workforce worked in other buildings than the 4 betatron
buildings. And workers there were 5 also exposed to uranium along the whole long
6 uranium pathway whereby it was transported 7 from the weighing scales. 8

We know that everything was 9 weighed that went into and out of the plant. 10
Inspectors had to look under the tarps to make 11 sure what was on those
transport vehicles. We 12 have operations at the loading dock. We have 13 a
transfer to rail cars. We have transport 14 along the rail tracks through
buildings 5, 15 through 10. And then the railroad tracks ran 16 into the old and
new betatron buildings so 17 that the actual areas that were surveyed for 18
uranium were a tiny fraction of the whole area 19 that formed the volume and the
space along the 2 uranium transport pathway. And, as David

p48

1 sampling, breathing zone samples, process 2 sampling for uranium ever at GSI
or by DOE 3 until that 1993 survey. 4

Okay. If I could go to the slide 5 3? 6

CHAIRMAN MELIUS: And, Dan, I'll 7 ask you to please move it along. 8


McKeel

EXHIBIT 1

GSI SEC-105 talk to
ABRWAH in Knoxville

12-11-2012


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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concems under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this transcript is for information only and is subject to change.

here for the residual period, I think, is that
the residual period applies to everybody in
the workforce. And most of the people in the
workforce worked in other buildings than the
betatron buildings. And workers there were
also exposed to uranium along the whole long
uranium pathway whereby it was transported
from the weighing scales.

We know that everything was
weighed that went into and out of the plant.
Inspectors had to look under the tarps to make
sure what was on those transport vehicles. We
have operations at the loading dock. We have
a transfer to rail cars. We have transport
along the rail tracks through buildings 5,
through 10. And then the railroad tracks ran
into the old and new betatron buildings so
that the actual areas that were surveyed for
uranium were a tiny fraction of the whole area
that formed the volume and the space along the

uranium transport pathway. And, as David

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS,
1323 RHODE ISLAND AVE., N.W.

(ON 924 AAW AMA CUINIZ TAR RAP 9AAnE 27n4

47



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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader shculd be
cautioned that this transcript is for information only and is subject to change.

radiologic survey of the new betatron
building. That was done by the GSI radiation
safety people and they used an 80-curie
cobalt-60 source, where the main work done in
that building, of course, was with a 24 or -5
MeV betatron. So the source they used to
model the building was not the source that was
primarily used in that building.

Then they also had = additional
Landauer film badge data on 19 radiographers
during that period from July 1, 1966 to 1973
late or early '74, when GSI ceased operations.
And, of course, that was a much_= smaller
percent of the workforce.

And, then finally, the data that
they had that Dr. Ziemer mentioned was when
Bechtel came in and did a radiologic survey of
the old and new betatron buildings. And ORNL
surveilled that. And this was done for DOE
under the FUSRAP program. They only surveyed

the new and old betatron buildings, did not

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLANO AVE., N.W.

45



DM_PublComment_12.11.12.rtf

PUBLIC COMMENT — DAN MCKEEL
-- 12/11/12 —
Good afternoon again.
I want to respond to several points just made in the
GSI SEC session that I feel need to be corrected

immediately and put on the record.

[1] David Allen and DCAS’ suggestion that recommending an
SEC for the early years 1953-62 might actually be a BAD
THING and be “claimant unfavorable,” was the way he put it,
is misleading to GSI and other claimants. Larry Elliott,
former DCAS director told me the same tall tale way back in
2005. Since then I have checked out this proposition that
seemed incredible to me at the time and it certainly has
turned out to be “not true” in practice.

Compare EEOICPA compensation history for the GSI and
Dow IL “sister sites” right next to one another. GSI has
twice as many claims, cases, and DR completed, yet the
total Part B compensation amounts are $10 million+ dollars
at GSI with no SEC and a far longer covered period,
compared to $17+ million dollars at Dow with a 1957-60 SEC.
I have had it confirmed by many observers that SEC sites do
far better compensation-wise despite the 22 SEC cancer
restrictions.

And Mr. Allen speculated on the types of cancers GSI

claimants might have, a fact that he doesn't really know.

2. David Allen’s answers to member Richardson's questions
about non-radiographers being assigned higher doses that
Betatron doses was not accurate or complete. In 2012 the

SC&A assigned dose for GSI “layout men,” a term Allen did


And 19 nobody knows what mixture was sent to 2@ Mallinckrodt, although I did
introduce a

p42

1 product sent from Mallinckrodt to GSI was 2 dingots. And that would be the
3,3@0-pound 3 metal. 4 Anyway, the first thing I wanted 5 to do in the first two
slides is to review the 6 real data that is available right now for the 7 AEC
operational period at GSI from 1953 to 8 June 1966. 9 And it really comes down
to three 10 data pieces. The first was there were 11 Landauer film badges on 89
radiographers 12 between November 1963 and 1966, June. This 13 represents only 3
percent of the workforce of 14 3,000 people, represents 1 job out of 15
hundreds. The radiographers did not wear 16 their badges outside the betatron
buildings. 17 As a matter of fact, in the 2012 modeling of 18 betatron doses
they were not even assigned 19 the highest external doses. And so that's 20
point one, very limited and nonrepresentative

p43

1 the entire period from 1953 to 1966, in June. 2

In 1962, there was a one-time 3 survey by GSI personnel of photons in the 4
building 6 radiography room from a cobalt-6@ 5 source. I'm sorry. The 1962
survey was by 6 not by GSI personnel but by the Nuclear 7 Consulting
Corporation. 8

And then the third piece of real 9 data they had in the operational period is 10
they have a series of purchase orders from 11 Mallinckrodt for uranium that
extended from 12 March 1958 through June 1966. There were no 13 purchase orders
found for 1953 through 14 February 1958. So there was no real data on 15 the
uranium source term for those years of the 16 covered period. There was only an
17 extrapolation, back extrapolation, from 1958 18 forward as to what might have
been present. 19

I need to comment that there was a 2@ comment made by Dave Allen in Appendix BB
and

p44

1 they made on the uranium. And that really 2 goes against what we know about
those 3 operations. They, in fact, did send with 4 every item radiographed with
the betatrons a 5 checklist of findings. 6

Now, that's not the final report. 7 Mallinckrodt may well have analyzed that 8
further, and I'm sure they did. But the point 9 is that all of the Mallinckrodt
GSI contract 1@ work records, which must be voluminous, every 11 one of those
has been lost. We don't have any 12 shipping manifestations -- manifests. We 13
don't have any weights. We don't have any 14 X-ray records. So that's the
operational 15 period real data. 16

Now, on slide 2, I review the real 17 data on residuals contamination period
between 18 July 1, '66 and 1993. And, again, that boils 19 down to three items,
three first bullets, and 2@ the comments by me. They had a one-time 1971

p45


GSI an SEC today.
Thank you. -- Dan McKeel 12/11/12

NOTE: Chairman Melius responded to Dan McKeel the “public
process” would have to take place before claimants could be
notified of the final vote tally on the GSI SEC. The
claimants may not, or admittedly will not be able to learn
about the final SEC-00105 vote until the next Advisory
Board meeting “next year,” no date mentioned. I was the
only person in the ABRWH venue hotel room or on the phone

to make a Public Comment this day.


OAN MCKEEL LIST OF EXHIBITS 1-7 (December 14, 2012)

EXHIBIT 1 is Dan McKeel’s verbal presentation to the ABRWH about GS! SEC-00105 on
12/11/12 when it met in Knoxville, TN. This presentation was delivered just before the full Board
voted 7 aye and 6 nay with other members absent at the time of the final full Board vote on
SEC-00105. The absent members, who include Drs. Poston (work group member), DR. Lockey,
and Mike Gibson, may not get to see an official ABRWH 12/11/12 meeting transcript before
they cast a final vote.

EXHIBIT 2 a PDF format slide presented 9/19/12 and 12/11/12 to the full Board that highlights

large differences in GSI external dose assignments by SC&A and NIOSH computer models to

Betatron operators and other workers, including layout men, comparing 2008 with 2012 results.
This same slide results were also discussed in detail at the TBD-6000 work group meetings on
March 15 and 28, 2012, June 2012, 8/28/12 and 11/28/12.

EXHIBIT 3 is PDF file of Dan McKeel's protest letter read into the record by DFO Ted Katz
when the GSI! SEC co-petitioner resigned from active participation in the TBD-6000 work group
meeting held on 11/28/12. The letter states his reasons why he withdrew.

EXHIBIT 4 is a PDF file of Dan McKeel’s Public Comment made on the record immediately
following his presentation at the ABRWH 12/11/12 meeting in Knoxville, TN

EXHIBIT 5 is a PDF bibliographic listing of 38 technical review and informational papers about
GSI that Dan McKeel has created and delivered to the TBD-6000 work group and full ABRWH
between 2007 and 2012. The active URL links and titles come directly from the DCAS website
listing for Docket 140 (GSI).

EXHIBIT 6 is the Powerpoint (PDF version) presentation made to the full ABRWH on
September 19, 2012, in Denver, Colorado.

EXHIBIT 7 is two PDF versions of Dan McKeel’s Board testimony on pages 39-53 of the 340
page ABRWH meeting court reporter transcript for 9/19/12. One version is formatted as is the
original transcript and contains the first 5 pages of the transcript and the last two as well. The
second version is copy/pasted to produce a more compact new version with the exact same
content. The reader may prefer whichever version is more comfortable for them to read.

Respectfully submitted,

: a} (iPS
SLA Oot
wypcoh CMC e2t o
Daniel W. McKeel, Jr, MD «12/14/2012

GSI SEC-00105 co-petitioner
Founding member SINEW



This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concems under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information has
been redacted as necessary. The transcript, however, has not been reviewed and certified by the Chair

of the Advisory Board for accuracy at this time. The reader should be cautioned that this transcript is for
information only and is subject to change

Public Comment 301
5

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.



Daniel W. McKeel, Jr., MD

General Steel Industries (GSI)
SEC-00105 Co-petitioner
September 19, 2012



The purpose of this assemblage of 7 Dan McKeel documents is to serve as reference
for those Board members who missed the GSI SEC-00105 83.13 petition vote by the full

Daniel W. McKeel, Jr., M.D.
GSI SEC-00105 co-petitioner

Documentation of McKeel Presentations
at the September and December 2012
ABRWH Meetings 86 & 87 and the
November 28, 2012, Meeting of

the TBD-6000 Work Group
--December 14, 2012--

Board on September 19, 2012, in Knoxville, TN. These documents will also be

submitted today to NIOSH Docket 140 (General Steel Industries AWE site) for posting

on the DCAS website: www.cdc.goviniosh/ocas.

1O GSisec ABSSENTEES 12.11.12

a

I>

The PDF files 01-07 comprise the documents in the current 9.14.12 submission in the

a

EXHIBITS 140 12.14.12
2) OL_TALK 12.11.12

=) MCKEEL_ABRWH_12.11.12f3b.odf

’ O2_SLIDE SCA v NIOSH
[P) SLIDE_Sep2012_SCAWNIOSH. grab
03_RESIGN LTR
=) DWM_resignTBD6Kwg_11.28.12.pdf
04_DM PUBL COM 12.11.12
=) DM_PublComment_12.11.12.odf
O5_DM PAPERS BIBLIO
“) McKeel_GSiPapess_2007-2012.pdf

2 O6_TALK 9.19.12

) ABRWHsep2012_mckeel0912fc.pdf
O7_DM 9.19.12tr PP 39-53

“=) ABRWH_86th_tr091912. pdf

“S) ABRWH_86th_tr091912pp39-53.pdf
a DWM_9.19.12_abrwh_p39-53.txt

attached file named: McKeel_GSI_9.14.12.pdf.


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This transcript of the Advisory Board on Radiation and Worker Heatth, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this transcript is for information only and is subject to change.

that the models that GSI --- for the GSI
betatron and layout workers that SC&A and
NIOSH had generated in 2008~2012 didn't agree
with each other at those times, and they
flip-flopped.

Whereas in 2012, the layout
workers had a low dose assigned by SC&A, by
2012, the SC&A layout dose had gone to 9.2 and
the NIOSH layout dose was only 1.02 to 2. So
they didn't agree with each other at that
time.

And, finally, you can see in slide
5 -- I apologize. I am going to go to slide
6. I am going to go to slide 5, finish this
up quickly.

It is often said there was a
robust, relatively robust, radiation safety
program between 1963 and 1966 and during part
of the residual period at GSI. And we have
just given you evidence now that I don't think

that was true compared to other sites. I sent

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE. N.W.

50



This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information has
been redacted as necessary. The transcript, however, has not been reviewed and certified by the Chair
of the Advisory Board for accuracy at this time, The reader should be cautioned that this transcript is for
information only and is subject to change.

UNITED STATES OF AMERICA
CENTERS FOR DISEASE CONTROL
tet et

NATIONAL INSTITUTE FOR
OCCUPATIONAL SAFETY AND HEALTH

tte tt

ADVISORY BOARD ON RADIATION AND
WORKER HEALTH

ttt et

86th MEETING

+e tt

WEDNESDAY
SEPTEMBER 19, 2012

++ et +

The meeting convened at 8:30 a.m.,
Mountain Daylight Time, in the Denver Marriott
Tech Center, 4900 South Syracuse, Denver,
Colorado, James M. Melius, Chairman,
presiding.

PRESENT:

JAMES M. MELIUS, Chairman
HENRY ANDERSON, Member
JOSIE M. BEACH, Member
BRADLEY P. CLAWSON, Member
R. WILLIAM FIELD, Member
DAVID KOTELCHUCK, Member
RICHARD LEMEN, Member
JAMES E. LOCKEY, Member
WANDA I. MUNN, Member

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
4323 RHODE ISLAND AVE. N.W.



ire)

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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this transcript is for information only and is subject to change

film badge data by radiographers only during
the entire period from 1953 to 1966, in June.

In 1962, there was a one-time
survey by GSI personnel of photons in the
building 6 radiography room from a cobalt-60
source. I'm sorry. The 1962 survey was by
not by GSI personnel but by the Nuclear
Consulting Corporation.

And then the third piece of real
data they had in the operational period is
they have a series of purchase orders from
Mallinckrodt for uranium that extended from
March 1958 through June 1966. There were no
purchase orders found for 1953 through
February 1958. So there was no real data on
the uranium source term for those years of the
covered period. There was only an
extrapolation, back extrapolation, from 1958
forward as to what might have been present.

I need to comment that there was a

comment made by Dave Allen in Appendix BB and

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.

43



Slide 3

TITLE: Key GSI events during the residual period 1966-1993

OBB had been power washed and cleaned in 1973 and 1984;
NBB had been power washed/cleaned and renovated for offices
in 1973, August 1978, and 1984;

National Steel taught classes in the New Betatron Bldg. offices;

Multiple companies used former GSI buildings for operations:

a) 5 and 6 for steel “pickling” (conc. acid cleaning) rolled steel:
Granite City Pickling & Warehouse from 1984 to present;

b) 8, 9 and 10 for “slitting” steel rolls: Michigan Metals Process-
ing (1978 through 1981) and Affiliated Metals (dates uncertain).
Overhead crane w/magnet to clean dust from GSI Bldgs. 5 --> 10.

Muitiple users and intermittent operations = massive dust disturbance

that make accurate modeling and bounding difficult or impossible.



them and no one has been compensated. Those AWE sites and the Weldon Spring DOE site are
judged by SC&A and DCAS to be “stringently justified” as being comparable to GSI. This is
scientifically ludicrous and offensive! It is definitely scientifically indefensible in my opinion.

Also, the authors of the November 25, 2012, SC&A review of Allen 11/6/12, continue to
insist that uranium ingots and dingots sent from MCW to GSI had only a few uranium oxide
flakes on their pure uranium surfaces that were easily rubbed off. The petitioners and site experts
have proven beyond a reasonable doubt, using technical publications and photographs, that
MCW-Destrehan Street and Weldon Spring site uranium dingots of the type sent to GSI for NDT
radiography were rough surfaced and taller than they were wide before cropping. SC&A ignores
the proven fact that the adherent magnesium-fluoride slag or crust of MCW uranium ingots and
dingots sent to GSI 1953-1966 contained radioactive daughter products of uranium and Betatron
activation products. The DCAS term “cold uranium” is inappropriate. SC&A and DCAS
continue to ignore the well substantiated fact that GS] NDT Betatron radiography defined the
interface between pure MCW uranium and the tightly adherent crust. Detecting structural flaws
competed with this prime MCW/AEC directive. Objective science has been abandoned to the
detriment of GSI claimants. Please refer to NIOSH Docket 140 for more documentation of
statements in this letter.

Thank you for this added opportunity to set the record straight.

Reference: OCAS-IG-003, Rev 0, 11/05/2007, 11 pages, title: “Radiation Exposures Covered for
Dose Reconstructions under Part B of the Energy Employees Occupational Illness
Compensation Program Act” (Approval: James W Neton, Concurrence: LJ Elliott)

See

Daucel WM efeet, Ye.

Daniel W. McKeel, Jr., M.D. 11/27/12


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This transcript of the Advisory Board on Radiation and Worker Health. Board Meeting, has been
reviewed for concems under the Privacy Act (5 U.S.C. § 552a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this transcript is for information only and is subject to change.

you the radiation safety program at the
Watertown Arsenal, which also was in
compliance with AEC regulations in about the
same time period as GSI's operational period.
And they were far more extensive than anything
that was done at GSI.

I have pointed out that NIOSH has
no valid uranium intake model for the whole
operation and residual periods. NIOSH didn't
want to use SC&A's alternate model. In my
opinion, the new surrogate data that NIOSH has
proposed really would probably not pass the
surrogate data criteria for the same reasons.
There were two slug facilities and one billet
facility. And there were no dingot facilities
similar to GSI and the use of Mallinckrodt
uranium.

And the other thing is none of the
relevant records that would contribute to the
accurate bounding have been recovered from

Mallinckrodt on the work done at GSI.

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.

PN AAA AAD ALA CLIO TAR AAP aaanc 27A4

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This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been
reviewed for concems under the Privacy Act (5 U.S.C. § $52a) and personally identifiable
information has been redacted as necessary. The transcript, however, has not been reviewed and
certified by the Chair of the Advisory Board for accuracy at this time. The reader should be
cautioned that this transcript is for information only and is subject to change.

handling being a relatively low-dose exposure
scenario, I will point out that one of the
main references cited by NIOSH and SC&A from
TBD-6000 is that by Adley, et al., for the
Hanford melt plant in 1952. And that showed
that uranium rod handling caused intake doses,
I quote, intake doses 2.5-fold higher than the
permitted limits. So they may have been
relatively low, but they were two and a half
times what radiation safety limits at the time
would permit.

So I thank you and appreciate your
attention.

CHAIRMAN MELIUS: Is the
co-petitioner on the line and wish to comment?

MS. JESKE: This is Patricia
Jeske. And no, I don't have any comments. I
do agree with Dr. McKeel. And I do hope that
we can reach a vote and put closure to this
for all of our Class Members. I appreciate

everybody's help. Thank you so much.

NEAL R. GROSS
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.

53



not use once, was 9.2 REM/year compared to 0.7 REM per year
for Betatron operators. In 2008, SC&A’s assigned doses for
Betatron operators in the SEC ER were 10-fold higher than

for other GSI workers. I have shown these comparative data

to the Board in September.

3. Mr. Allen repeatedly referred to NIOSH always
using the scenario that gave the highest assigned dose in
their dose reconstructions. This is simply NOT TRUE based
on GSI DRs I have seen. The non-radiographers often get the
lower of two doses Appendix BB specifies. Everyone is NOT

assigned the Betatron operator dose.

4. David Allen has replied by an e-mail I have seen
to a GSI Docket 140 contributor, who I won’t name because
it will be redacted from the transcript, that the future
Rev 1 revision of Appendix BB will result in lower assigned
total dose for many claimants, so there won’t be that many
reopened denied claims that will be reworked and approved
for compensation. Allen’s reason: NIOSH will be doing far

more “best estimate DRs in APPENDIX BB.”

There are many other points I would like to have added
to or to have rebutted, however I will reserve those for a
later time.

My final comment is, it is a shame that GSI claimants
have to wait perhaps weeks to learn the outcome of today’s
final vote. My question to Mr. Katz and the Board that
maybe they can answer now, is how will GSI claimants be
informed of the Board’s final SEC-00105 decision? I want
to sincerely thank all members who did do the right thing

and vote NO to NIOSH’s ill conceived recommendation to deny